ARCHIVED - Emera Brunswick Pipeline Company Ltd. - Audit Report OF-Surv-OpAud-E236 01 - Appendix III: EBPC Environmental Protection Program Audit Evaluation Table

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Appendix III
EBPC Environmental Protection Program Audit Evaluation Table

 

1.0 POLICY AND COMMITMENT

1.1 Policy and Commitment Statements

Expectations: The company shall have a policy approved and endorsed by senior management (the Policy). It should include goals and objectives and commit to improving the performance of the company.

References:[1]
OPR-99 sections 4 and 48
CSA Z662-07 Clause 10.2.2

Assessment:
EBPC representatives indicated that Emera Inc., its parent company, has developed its own environmental management system which applies to all its companies. Further, EBPC identified that it had reviewed the Operator’s policy to ensure consistency with its own. The Operator’s Policy and Charter provides adequate direction and commitment to environmental protection.

The policy was available at all workplaces and on the Operator’s primary intranet site and interviews confirmed that employees understood the policy and its application in their work.

Compliance Status: Compliant

[1] Each “Reference” in this table contains specific examples of the “legal requirements” applicable to each element but are not necessarily a complete list of all applicable legal requirements.

2.0 PLANNING

2.1 Hazards Identification, Risk Assessment and Control[2]

Expectations: The company shall be able to demonstrate a procedure to identify all possible hazards. The company should assess the degree of risk associated with these hazards. The company should be able to support the rationale for including or excluding possible risks in regard to its environment, safety, integrity, crossings and awareness and emergency management and protection programs (management and protection programs). The company should be able to implement control measures to minimize or eliminate the risk.

References:
OPR-99 sections 4(2) and 48
CSA Z662-07 Clause 10.2

Assessment:
As part of an Operations and Maintenance (O&M) Agreement between EBPC and its Operator, the Operator is implementing and maintaining the Environmental Protection program (EPP).

Interviews and document review indicated that the Operator is aware of the majority of the environmental hazards and aspects which could be associated with Brunswick Pipeline facilities. At the time of the audit, the Operator relied primarily on hazards identified for the project application and construction activities as opposed to an analysis of the hazard associated with or introduced by operations activities. The Operator also identified that it relies on its staff to proactively identify environmental hazards and aspects during pre-job analysis and contract development processes. A third source of hazard identification for operations were its measurement and monitoring activities (inspections and aerial patrols). Hazards identified through patrols were integrated into the Safety Evaluation Process and are applied to all environment, health and safety (EHS) processes.

The Operator’s continued reliance on hazard information acquired during the application phase is an acceptable practice. Given the facilities are only a few years old, the present processes are adequate and use of information developed during the application and construction process is a prudent practice. However, the incorporation of the pre-existing and newly identified hazards should be more formally managed and documented. More specifically, confirmation of continued adequacy of data and methodologies should be done and formal links or requirements to application data should be incorporated into existing processes. If this integration of new and existing information is not done, the Operator risks not being in compliance in the future. In order to ensure and confirm the ongoing suitability of the processes, the construction processes should be reviewed, revised and formally adopted for the operation phase.

During the audit, the Operator provided evidence that it was updating its EHS procedures. This update included a formalized Operations Controls Table which systematically reviewed the regulated activities and identified potential controls for each issue or hazard. This process, while not being complete or implemented at the time of the audit, was viewed as appropriate to meeting the majority of the Board’s requirements for this element.

Therefore the Board recommends that the Operator ensure the complete the implementation of the Operations Control Table into the hazard identification processes to ensure environmental aspects for its operations and maintenance activities are appropriately addressed in procedures.

Compliance Status: Compliant with recommendation

[2] Hazard: Source or situation with a potential for harm in terms of injury of ill health, damage to property, damage to workplace environment, or a combination of these. Risk: Combination of the likelihood and consequence(s) of a specified hazardous event occurring

2.2 Legal Requirements

Expectations: The company shall have a verifiable process for the identification and integration of legal requirements into its management and protection programs. The company should have a documented procedure to identify and resolve non-compliances as they relate to legal requirements which includes updating the management and protection programs as required.

References:
OPR-99 sections 4, 6 and 48
CSA Z662-07 Clause 10.2.2(g)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

Interviews with EBPC staff indicated that, while its staff monitors general NEB requirements, it relies on the Operator to develop and implement a process to identify and manage compliance issues and facilities.

Interviews with the Operator’s representatives indicated that it did not have a process for the formal and systematic identification of all of the applicable legislative and regulatory requirements which apply to the facilities. Lack of a demonstrated process does not necessarily identify lack of compliance; however, a formal process allows for a clear demonstration and assurance of compliance.

Interviews indicated that Operator staff are generally aware of legal requirements and apply them as required. Presently, the Operator’s staff remains current with company expectations through involvement with industry organizations and legal subscriptions.

While the Operator was unable to provide appropriate legal lists as described above, staff indicated that, as part of the Operator’s internal HSE audit processes, legal lists are developed for inclusion in the audit protocols applicable to individual audits and therefore act as a form of legal review. The Operator provided an example of a legal list developed for implementation of other NEB regulated facilities’ audits. Examination of these documents indicated that they were not exhaustive of all required legislation and some applicable regulatory requirements were not included.

As further demonstration of its compliance, the company provided the NEB with additional information following the issuance of the draft audit report which asserted that the procedures and commitments contained within its construction and operations environmental protection plan (EPP) included the necessary environmental compliance requirements. Further, this information had been vetted through the NEB approval process as a measure of its compliance. The Board notes that, while the EBPC EPP was reviewed for compliance during the application process, as part of its environmental protection program requirements, the company must develop and implement documented processes to actively monitor and integrate legal requirements on an on-going basis in order to ensure continued compliance.

Compliance Status: Non-compliant

2.3 Goals, Objectives and Targets

Expectations: The company should have goals, objectives and quantifiable targets relevant to the risks and hazards associated with the company’s facilities and activities (i.e. construction, operations and maintenance). The objectives and targets should be measurable and consistent with the Policy and legal requirements and ideally include continual improvement and prevention initiatives, where appropriate.

References:
OPR-99 section 48
CSA Z662-07 Clause 10.2.2(h)(ii)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP. The Operator’s EHS policy contains generalized goals and objectives for its EHS management system (EHS MS). The policy contained action plans and objectives set out by the Operator’s Operations Committee, EHS Committee, as well as management and individual staff’s personal safety action plans.

The membership of the Operations Committee and the EHS Committee consists of Vice Presidents of the various divisions. The committee provides reports and updates to the Operator’s senior management for review. As part of the implementation of the EHS programs, EHS goals, targets and objectives have been identified for all staff and are included in individual job descriptions. Employees are measured and are recognized for meeting EHS performance objectives as part of the “Short Term Incentive Programs”.

The Board identified that goals, objectives and targets, while managed appropriately, only marginally meet the present minimum requirements to be compliant and could be improved to address issues more relevant to EBPC operations and could better reflect measurable improvement of effectiveness of technical programs. It was noted that the goals focussed on broader regional issues such as improvements to compression related issues and issues more focussed on the North East (NE) United States (U.S.) facilities where the majority of the Operator’s activities are. Presently there are no compression facilities in Canada; therefore, the goals do not fully reflect the Brunswick Pipeline facilities.

The goals, targets and objectives are considered only marginally compliant in that they exist but are so general that they do not accurately reflect the technical programs and were not considered to apply specifically to Brunswick Pipeline operations.

Therefore, the Board recommends that the Operator demonstrate an ongoing process for monitoring goals, targets and objectives relevant to its Canadian facilities and programs to promote continual improvement requirements.

Compliance Status: Compliant with recommendation

3.0 IMPLEMENTATION

3.1 Organizational Structure, Roles and Responsibilities

Expectations: The company shall have an organizational structure that allows its management and protection programs to effectively function. The company should have clear roles and responsibilities, which may include responsibilities for the development, implementation and management of the management and protection programs.

References:
OPR-99 section 48
CSA Z662-07 Clauses 10.2.1 and 10.2.2(b)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP. The Operator has established an EHS Management Team with specific accountability for the EPP. Copies of job descriptions were reviewed to confirm that specific EHS responsibilities and accountabilities had been included. The development of an appropriate structure and roles and responsibilities for field activities was also verified. By examining organization charts, it was identified that the lines of reporting for EHS issues are clearly outlined, and include reporting routes which includes the Vice President, Operations NE Transmission; Manager, NE-Health & Safety; EHS Support Specialist. Overall accountability for EHS issues is maintained by the Spectra EHS Committee (EHSC) which is comprised of senior EBPC personnel as well as representatives from the Operator’s Board of Directors. The Operator was able to demonstrate through documentation that this committee is functioning as planned. Quarterly records of reviews conducted by this committee were reviewed as part of this audit.

It was noted that the organization and implementation of environmental procedures and practices at the field lies with the EHS Support Specialist with assistance of the regional Lands, Emergency Planning and Public Awareness Coordinators and the Operations Technicians. However, the audit was unable to verify that a formal, current job description existed for the EHS Support Specialist which included clearly articulated responsibilities and authorities. Based on staff interviews, it was clear that in practice the responsibilities were well understood. As well, document review of field staff job descriptions indicated that environmental roles and responsibilities were not fully documented. Interviews with Operator regional staff confirmed that the structure in practice was appropriate and reporting relationships were clear. However, job descriptions should be formalized and the various needs including training, reporting structure, etc. be more formally managed.

After the document review and interviews, the audit also identified that the expectations of the EHS Support Specialist appeared to be significant for one person to manage and sustain. It was noted that the EHS management workload involved review and development of new practices and procedures and included oversight of activities involving contract management and on-sight activities.

The Operator did not demonstrate that it had formally identified and defined environmental responsibilities for the EHS Support Specialist and regional technical staff that have key roles in the implementation of the EPP. As well, it is recommended that the Operator review the resourcing of EHS oversight to ensure that environmental protection can be maintained.

Compliance Status: Non-compliant

3.2 Management of Change

Expectations: The company shall have a management of change program. The program should include:

  • identification of changes that could affect the management and protection programs;
  • documentation of the changes; and
  • analysis of implications and effects of the changes, including introduction of new risks or hazards or legal requirements.

References:
OPR-99 section 6
CSA Z662-07 Clause 10.2.2 (g)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

The Board noted that a Management of Change (MOC) process is in place which outlines the process to be followed for identifying, assessing and implementing changes once they have been approved by the responsible individuals (EHS MS Management of Change Performance Standard 2.7). The Board also noted that there is currently a collaborative process to review all Standard Operating Practices (SOPs) against all applicable regulatory requirements and best practices (Canadian and U.S.). The EHS group is leading this process with support of senior management, and regional subject matter experts.

Despite the existing efforts being put in place for MOC, it could not be verified that the Operator had a fully compliant and implemented MOC procedure for the EHS program that included proactive, formal identification of required changes and analysis of the effects that the changes may have on related processes. The audit identified that the present MOC process is only partially implemented by various corporate technical area s (e.g. Safety, Environment, Engineering and Construction). Review of the Operator’s internal audit documentation for similar facilities identified issues with the implementation of the MOC and included plans for a corrective action.

The Operator could not demonstrate an adequate MOC was a fully implemented process for the Brunswick Pipeline facilities and activities.

Compliance Status: Non-compliant

3.3 Training, Competence and Evaluation

Expectations: The company shall have a documented training program for employees and contractors related to the company’s management and protection programs. The company shall inform visitors to company maintenance sites of the practices and procedures to be followed. Training requirements should include information about program-specific policies. Training should include emergency preparedness and environmental response requirements as well as the potential consequences of not following the requirements. The company should determine the required levels of competency for employees and contractors. Training shall evaluate competency to ensure desired knowledge requirements have been met. Training programs should include record management procedures. The training program should include methods to ensure staff remains current in their required training. The program should include requirements and standards for addressing any identified non-compliances to the training requirement.

References:
OPR-99 sections 28, 29, 30(b), 46, 48 and 56
CSA Z662-07 Clause 10.2.2(c)

Assessment:
According to the O&M agreement between EBPC and the Operator, the Operator is responsible for training of employees with EPP roles and responsibilities.

The Operator maintains records of all training required and completed by all workers. A training matrix applies to employees assigned to operating and maintaining the EBPC pipeline including the environmental responsibilities. This matrix consists of a list of core training courses and the frequency with which they are required. Administrative procedures in place notify employees of any updates to this matrix should additional training requirements be identified or should existing curricula be changed. Document review confirmed that the Human Resources Orientation checklist includes an EHS component and completion of the various components requires manager’s sign off.

The Operator’s environmental training matrix was reviewed and it was found to be primarily focused on frontline staff (Operations Technicians) and that it did not include refreshment requirements for senior staff with environmentally related roles. It was also noted that here were no training or competency requirements for the Operator’s professional staff (EHS Support Specialist). This gap was considered significant as the majority of the environmentally related activities are coordinated or undertaken in this senior position.

This element was evaluated as non-compliant due to the need to develop and implement on-going training requirements for all staff with environmental responsibilities.

Compliance Status: Non-compliant

3.4 Communication

Expectations: The company should have an adequate, effective and documented communication process(es):

  • to inform all persons associated with the company’s facilities and activities (interested persons) of its management and protection programs policies, goals, objectives and commitments;
  • to inform and consult with interested persons about issues associated with its operations;
  • to address communication from external stakeholders;
  •  for communicating the legal and other related requirements pertaining to the management and protection programs to interested persons;
  • to communicate the program’s roles and responsibilities to interested persons.

References:
OPR-99 sections 18, 28, 29 and 48
CSA Z662-07 Clause 10.2.2(d)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

The Operator was able to demonstrate that it employs many methods for communicating environmental requirements with its internal and external stakeholders. Communication of EHS information takes place during safety stand down meetings; quarterly employee meetings and safety updates; daily tailgate meetings; daily and weekly safety reports; NE Region Health and Safety Newsletters; monthly safety and communications meetings; monthly reports to EHS Corporate group; contract management activities, pre-job meetings, its intranet sites; etc.

The Operator could not demonstrate that it has an overarching communication plan that formally identifies and outlines the distribution of various types of information to appropriate parties. While interviews confirmed communication is occurring throughout technical networks and through the means identified above, without a formal communication plan, the Operator cannot ensure that all stakeholders and interested parties are receiving the appropriate information in a timely fashion.

The Board noted that Emera Inc.’s internal environmental management system requirements outlines requirements for this plan, which, if implemented as designed and in conjunction with the Operator’s plan should result in a fully compliant communication plan.

As the EPP communication plan was not implemented at the time of the audit, the Operator is found to be non-compliant.

Compliance Status: Non-compliant

3.5 Documentation and Document Control

Expectations: The company should have documentation to describe the elements of its management and protection programs- where warranted. The documentation should be reviewed and revised at regular and planned intervals. Documents should be revised immediately where changes are required as a result of legal requirements or where failure to make immediate changes may result in negative consequences. The company should have procedures within its management and protection programs to control documentation and data as it relates to the risks identified in element 2.0.

References:
OPR-99 sections 27, 48 and 56
CSA Z662-07 Clause 10.2.2(e)(f)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

Document review confirmed that the Operator has implemented a comprehensive document management system which includes controlling and tracking all documents.  As well, the audit identified evidence that the documents are to undergo continual reviews and improvement which should include on-going monitoring, evaluation and updating of documents when required.

Despite the existence of document management practices, the audit noted that the Operator is continuing to use the EPP developed during the application process for direction in undertaking operational environmental activities. Even though this pipeline is in operations this practice was viewed as appropriate at this time, given the length of time that this line has been operating and considering that the right-of- way (RoW) is still technically in a post-construction phase from an environmental perspective.

However, the Board recommends that the Operator  develop and implement a process to regularly review, adopt and document those practices required for the operation and maintenance of the facilities to ensure that it continues to be fit-for-purpose and incorporates all legal requirements.

The Board notes that EBPC has filed additional information with respect to this issue as part of its comments on the NEB Draft Audit Report. In its comments EBPC indicated that its EPP will be revised only as submitted to the Board as per its undertaking during its application. The Board notes that it expects companies to maintain dynamic programs which identify, evaluate and control hazards on an ongoing basis. EBPC should therefore ensure that its programs are updated on a regular and appropriate basis to meet the Board’s expectations regardless of its filings with the Board.

Compliance Status: Compliant with recommendation

3.6 Operational Control - Normal Operations

Expectations: The company should establish and maintain a process to develop, implement and communicate mitigative, preventive and protective measures to address the risks and hazards identified in elements 2.0 and 3.0. The process should include measures to reduce or eliminate risks and hazards at their source, where appropriate.

References:
OPR-99 sections 27-49
CSA Z662-07 Clauses 10.2.2(f) and 10.3.1

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP. Further, the Operator provided working documentation for the revision of EHS management processes and procedures which included a formal EHS Operations Control Table. The Operator uses this table to document and manage the issues which require the implementation of a control to minimize its effects.

As noted in Element 2.1 and 2.2 above, the Operator has not demonstrated that it has compliant processes for identifying all of its legal requirements and environmental aspects and risks. As legal requirements and environmental risks are integral in normal operating conditions, the Operator could not demonstrate that they had identified all controls required to be developed to assure protection of the environment.As well, as noted in Documentation and Document Control (Element 3.5), the Operator was utilizing documents developed for construction activities as the primary procedures for the operation of the facilities.

As the Operator was unable to provide an adequate hazard identification process and document control procedures, it could not demonstrate that its procedures were adequately addressing all hazards. The Operator was unable to demonstrate whether it was anticipating and controlling its environmental risks appropriately.

Compliance Status: Non-compliant

3.7 Operational Control - Upset or Abnormal Operating Conditions

Expectations: The company shall establish and maintain plans and procedures to identify the potential for upset or abnormal operating conditions, accidental releases, incidents and emergency situations. The company shall also define proposed responses to these events and prevent and mitigate the likely consequence and/or impacts of these events. The procedures must be periodically tested and reviewed and revised where appropriate (for example, after emergency events).

References:
OPR-99 sections 32, 35 and 52
CSA-Z662-07 Clauses 10.3.2 and 10.3.5

Assessment:
From an environmental perspective, because of the product (sweet, dry gas) and the minimal above ground facilities, environmental impacts related to upsets would be limited to the effects of the failure of slopes at either upland or watercourse crossings, the effects of loss of integrity at water course crossings, the release of small volumes of operationally related wastes or Workplace Hazardous Materials Information System managed products, or an unintended release of product into the atmosphere. Control of these issues would consist of application of normal operating procedures and practices (see Element 3.6). No specific evaluation of this element was made as it relates to the EPP.

Compliance Status: N/A

4.0 CHECKING AND CORRECTIVE ACTION

4.1 Inspection, Measurement and Monitoring

Expectations: The company shall develop and implement surveillance and monitoring programs. These programs should address contract work being performed on behalf of the company. These programs should include qualitative and quantitative measures for evaluating the management and protection programs and should, at a minimum, address legal requirements as well as the risks identified as significant in elements 2.0 and 3.0. The company should integrate the surveillance and monitoring results with other data in risk assessments and performance measures, including proactive trend analyses. The company shall have documentation and records of its surveillance and monitoring programs.

References:
OPR-99 sections 39, 48, 53(1) and 54(1)
CSA Z662-07 Clauses 9.1.7, 10.2.2, 10.7.2.5, 10.7.2.6, 10.7.2.8 and 10.14.1

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

Document review and interviews confirmed that the Operator has developed and implemented many activities for measuring and monitoring the implementation of the EHS MS. This monitoring is captured and communicated in the following ways:

  • the development and review of daily and monthly progress reports;
  • daily and weekly safety inspection reports (which includes environmental concerns);
  • daily tool box meetings;
  • weekly all staff meetings;
  • weekly behavior based inspections;
  • incident reporting and review;
  • incident investigation where required;
  • monthly RoW aerial patrols;
  • annual full length RoW inspections (on-ground); and
  • completion of incident reporting (including environmental issues).

As part of its post-construction activities, the Operator was able to demonstrate that it reviews and evaluates the environmental success of the mitigation program applied during the construction of its facilities.

Although the Operator has procedures for various duties, the Board noted that staff were performing additional undocumented inspection activities as part of their everyday activities.  For instance, staff identified that when performing routine maintenance they were required to evaluate the environmental condition of the worksite. This evaluation is not documented in the procedure nor is it clear how the results are captured. In another similar example, the technical staff identified that they perform a full on-ground inspection of the RoW annually which was also not fully documented or appropriately recorded. While the Board concluded that both inspection activities are good and necessary practices, they exist outside the procedure and therefore could be accidentally discontinued.

The Board recommends that the Operator ensure the thorough and formal documentation of activities that record environmental issues, requirements and inspection activities into its report requirements.

Compliance Status: Compliant with recommendation

4.2 Corrective and Preventive Actions

Expectations: The company shall have a process to investigate incidents or any non-compliance that may occur. The company shall have a process to mitigate any potential or actual issues arising from such incidents or non-compliances. Such mitigation may include appropriate timing and actions for addressing the issues that arise. The company shall demonstrate that it has established  a documented procedure to:

  • set criteria for non-compliance;
  • identify the occurrence of any non-compliances;
  • investigate the cause(s) of any non-compliances;
  • develop corrective and/or preventative actions; and
  • effectively implement the required corrective and/or preventative actions.

The company should develop procedures to analyze incident data in order to identify deficiencies and opportunities for improvement in its management and protection programs and procedures.

References:
OPR-99 sections 6 and 52
CSA Z662 Clauses 10.2.2(g) and (h)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

The Operator was able to provide documents and records that demonstrated the development and implementation of appropriate incident management and investigation processes. Further, the Operator was able to demonstrate that it has adequate processes in place to identify, develop and implement corrective and preventative actions which arise from its incident investigations.

Compliance Status: Compliant

4.3 Records Management

Expectations: The company shall establish and implement procedures to ensure that the records supporting the management and protection programs are retained, accessible and maintained. The company shall, as a minimum, retain all records for the minimum lengths of time as required by the applicable legislation, regulation and standards incorporated by reference into the regulation.

References:
OPR-99 sections 48 and 56
CSA Z662-07 Clause 10.2.2(e)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP.

Records related to the EPP are kept in the regional offices. It was confirmed through documentation and record review that the Operator has implemented record retention processes which include appropriate types of records to be retained, retention and disposition timeframes and disposal methods. Copies of all records requested were made readily available.

Compliance Status: Compliant

4.4 Internal Audit

Expectations: The company shall develop and implement a documented process to undertake audits of its management and protection programs and procedures. The audit process should identify and manage the training and competency requirements for staff carrying out the audits. These audits shall be conducted on a regular basis.

References:
OPR-99 sections 53 and 55
CSA Z662-07 Clause 10.2.2(c) and (h)(iii)

Assessment:
As part of an O&M Agreement between EBPC and its Operator, the Operator is implementing and maintaining the EPP which includes internal auditing of the various programs. As a result of the relative newness of the facilities a full audit applicable to its operations environmental programs had not been completed at the time of the audit.

In order to assess the intended audit practice and program, the Board evaluated the requirements of the Operators’ audit process through the review of documents and records from internal audits conducted on the operator’s other NEB regulated facilities. It was confirmed that the Operator has an internal audit program developed and implemented as directed by management. The Operator indicated that it develops its audit specific content based on identified regulatory requirements and management system principles. There is mandatory follow-up and close-out of findings that are reported by internal third parties with company senior management holding responsible managers and staff accountable.

The review of the program indicated that, the internal audit program was well documented and being appropriately implemented and managed. However, the program was not meeting the requirements of OPR-99 as it did not include an assessment of the adequacy of the EPP in meeting the requirements of Section 48 of OPR-99 nor was the Operator able to demonstrate a formal and comprehensive identification and evaluation of all of EBPC’s regulatory requirements. Instead, the system relies on an informal, self identification of requirements by the facilities’ operating staff and management which does not allow for a systematic review of the requirements and could lead to missing requirements to remain unidentified and unmeasured.  Effectively, the audits completed presently are audits of conformance to the operator’s existing practices as opposed to audits of compliance against all of the regulatory requirements which are applicable as outlined in OPR-99.

The Board therefore recommends that the Operator amend its internal audit program to ensure requirements identified in OPR-99 and other referenced and regulatory documents are appropriately defined and that internal audits incorporate all regulatory requirements that apply to the Brunswick Pipeline and facilities. Further, during the audit, EBPC staff provided documentation of its parent company’s internal environmental management system which includes internal audit requirements. EBPC staff indicated that it was EBPC’s intention to ensure that practices implemented reflect the Emera Inc. environmental management system requirements. If EBPC implements its contemplated practices it could result in an effective and fully compliant process.

Compliance Status: Compliant with recommendation

5.0 MANAGEMENT REVIEW

Expectations: Senior management should formally review the management and protection programs for continuing suitability, adequacy and effectiveness. The review should be based on appropriate documentation and records including the results of the surveillance, monitoring and audit programs. This review should be formal and documented and should occur on a regular basis. The management review should include a review of any decisions, actions and commitments which relate to the improvement of the programs and the company’s overall performance.

References:
OPR-99 section 55
CSA Z662-07 Clause 10.2.2(h)(iii)

Assessment:
See Appendix VII for the assessment of this element.

Compliance Status: See Appendix VII for the assessment of this element.

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